After a Slow First Quarter, SEC Accounting and Auditing Enforcement Activity in 2020 Rebounds; PCAOB Activity Declines to New Low


Monetary settlements total more than $1.4 billion.

Los Angeles—In a year characterized by pandemic-related challenges and the potential for a change in U.S. presidential administration, Securities and Exchange Commission accounting and auditing enforcement activity remained strong, but Public Company Accounting Oversight Board auditing-related activity declined to a new low, according to a report released today by Cornerstone Research.

The Accounting and Auditing Enforcement Activity—2020 Review and Analysis reports that the SEC and PCAOB publicly disclosed a total of 63 accounting and auditing enforcement actions during 2020, of which nearly 80% were initiated by the SEC. Unlike SEC actions, which rebounded after a substantial first-quarter decline, finalized PCAOB actions did not return to pre-pandemic levels.

Accounting issues remained at the forefront of SEC enforcement, increasing by 10% compared to 2019.

The SEC initiated 50 enforcement actions involving accounting or auditing allegations in 2020, compared to 58 actions in 2019. The total number of respondents decreased from 76 to 70. The majority of SEC actions in 2020 involved SEC registrants and related individuals.

“After a steep decline in SEC accounting and enforcement activity in the first quarter of 2020, activity ramped up for the remainder of the year,” said Elaine Harwood, a report coauthor, senior vice president, and head of the firm’s accounting practice. “Accounting issues remained at the forefront of SEC enforcement, increasing by 10% compared to 2019.”

“The vast majority of SEC settlements were imposed after the June 2020 U.S. Supreme Court ruling in Liu v. SEC that authorized the SEC to seek disgorgement as an equitable remedy,” said Simona Mola, a report coauthor and senior manager at Cornerstone Research. “After that ruling, the average disgorgement was nine times larger than the average disgorgement imposed against firms earlier in the year.”

The PCAOB disclosed 13 audit-related actions, just over half of the number initiated in 2019. The number of respondents declined from 40 to 27. Almost two-thirds of the PCAOB actions in 2020 involved a firm and at least one individual auditor.

“The PCAOB also saw a steep decline in auditing enforcement during the first quarter of 2020, remaining below pre-pandemic levels throughout the year,” said Dr. Harwood. “The PCAOB finalized fewer actions in each quarter of 2020 than the corresponding quarter in each of the last three years, and PCAOB enforcement activity for 2020 as a whole was the lowest of any year since we have been reporting on the data.”

Both the SEC and PCAOB imposed monetary penalties against approximately three-fourths of respondents. Monetary settlements totaled more than $1.4 billion in 2020.

Of the 50 actions brought by the SEC in 2020, about one-third alleged revenue recognition violations and more than half alleged violations related to a company’s internal control over financial reporting.

The proportion of PCAOB actions in 2020 involving announced restatements and/or material weaknesses in internal control was 38%, more than double the 2015–2019 average. Only one PCAOB action involved revenue recognition.

Accounting and Auditing Enforcement Activity—2020 Review and Analysis

  • The SEC initiated 46 accounting and auditing actions in 2020 as administrative proceedings (92%). Only four actions were civil actions, and all but one were resolved by the end of 2020.
  • Total monetary settlements in SEC actions increased in 2020, but the median settlement fell from $4.1 million in 2019 to $3.4 million in 2020.
  • The percentage of non-U.S. actions brought by the SEC was lower in 2020 (14%) compared to 2019 (17%) but in line with the 2015–2019 average.
  • The percentage of PCAOB actions involving non-U.S. respondents in 2020 (8%) decreased substantially compared to 2019 (29%).
  • In 2020, for the second consecutive year, the PCAOB did not disclose any actions pertaining to audits of broker-dealers. In the prior four years, actions involving auditors and audit firms of broker-dealers comprised nearly 30% of all actions on average.


Jason Milch
Terri Viera
Cornerstone Research